Neil Dyson, Business Line Manager for Machinery Safety at TUV SUD Product Service, a global product testing and certification organisation, discusses the need for PUWER assessments, even on new machinery.
In our experience, many machinery owners assume that if their equipment has the CE marking that no further action is required. However, the Work Equipment Directive, which is implemented in the UK by the Provision and Use of Work Equipment Regulations 1998 (PUWER), applies to all work equipment regardless of its age, including equipment that carries the CE marking.
PUWER describes what an employer needs to do to protect employees in the workplace. It is therefore their responsibility to ensure that all machinery meets the requirements of the Machinery Directive and PUWER, of which risk assessments are an essential ingredient.
To identify any issues immediately, a thorough and correct risk assessment should be completed before any new machinery goes into operation. Problems can then be rectified with the manufacturer so that they or the machinery owner no longer run the risk of a prosecution under the Supply of Machinery (Safety) Regulations (which implement the Machinery Directive in the UK) or PUWER.
The Health and Safety Executive (HSE) states that if changes to machinery "are very substantial (eg significant new hazards and risks are introduced or new methods of control of the machine replace those previously provided, such as computer control of a previous manual machine) it may amount to being considered a 'new' machine (or new assembly), for which you must undertake conformity assessment" ('conformity assessment' here refers to the Machinery Directive, hence CE marking).
The HSE goes on to state that even if changes to machinery are not substantial, such as refurbishment, the owner must still ensure that it continues to meet the requirements of PUWER, as well as any other requirements which may also apply to the product.
Machinery risk assessment
The first step is to identify anything that has the potential to cause harm. Secondly, an assessment must be made of the likelihood of a person coming into contact with these hazards and how much damage it would cause (the severity of any injury).
Examples of hazards that have the potential to do harm include:
- A manipulating robot
- A moving conveyor
- A pallet wrapper
A risk assessment would normally be carried out for each hazard identified. The Preliminary Hazard Analysis (PHA) method uses a Hazard Rating Number system. Referencing a table, the most appropriate phrase that applies to the hazard is chosen, and the corresponding score results in a hazard rating number (HRN) that corresponds to the level of risk.
The PHA takes into consideration:
- The likelihood of a person or persons coming into contact with a hazard
- The degree of possible harm that could be caused
- The frequency of exposure
- The number of people at risk at the same time
Control measures can then be applied to mitigate the risk:
- Design-out the hazard
- Remove the need for man-machine interface
- Design-in safeguards
- Reduce the possibility of occurrence
- Reduce the degree of harm
- Warn and inform machine operators (but only if you can achieve adequate safety this way)
Once the control measures have been implemented, a reassessment must then be undertaken to ensure that the measures provide an adequate level of safety. The process is repeated until an adequate level of safety is achieved.
Section 6 of PUWER requires that inspections must be repeated 'at suitable intervals' if machines are exposed to conditions that may lead to deterioration. In reality, every machine is exposed to conditions that may lead to deterioration, so the requirement effectively means that they must all be regularly inspected.
Although risk assessments must therefore be conducted conscientiously and at appropriate intervals, we still visit sites that simply forget and have not taken any action for five years or more.
The answer here is to set up an internal process, overseen by an individual who ensures risk assessments are carried out according to an agreed schedule. Creating an internal procedure in this way successfully integrates risk assessment into the everyday working practices. It is not something that is stuck on a shelf and forgotten.
PUWER requires that the persons who determine the nature of the assessments and carry them out should be competent to do so. However, the failures we see on site are often due to a lack of appropriate internal expertise and physical resource to do an in-depth and correct assessment of all machinery. A decision to 'make do' or not invest in the appropriate expertise could result in expensive fines - or, worse still, prove fatal to machinery users.
Follow the link for more information about the PUWER assessments from TUV SUD Product Service.